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Introduction by Chair. Linda Crichton Head of Resource Management. Agenda. Materials Recovery Facilities (MRF) - Regulation. Richard Pullen Deputy Director – Waste Policy and Regulation Defra. Introduction.

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Introduction by Chair

Linda Crichton

Head of Resource Management



Materials recovery facilities mrf regulation

Materials Recovery Facilities (MRF) - Regulation

Richard Pullen

Deputy Director – Waste Policy and Regulation

Defra


Introduction
Introduction

This is a new Regulation, applying to MRFs and providing a framework for improving data on the sampling process/quality of recyclable material, showing how it is turned from this…..



Why are these regulations important
Why are these regulations important?

  • Ground-breaking - first set of regulations in place to improve transparency and information about quality of recyclable material produced by MRFs;

  • For first time, transparency of information on quality available to the wider industry. Will help market in recyclates to operate better and grow;

  • Information provided on quality of recyclate by MRFs, will be able to be used to help demonstrate compliance with separate collection requirements of revised Waste Framework Directive.


Where did we begin a potted history to the regulations
Where did we begin? A potted history to the regulations…

  • ESA started ball rolling with heir own (voluntary) accreditation scheme (Code of Practice);

  • Then extensive discussions with industry on:

  • Considering ways to try and help stimulate the market conditions necessary to improve and promote the quality of material produced by MRFs;

  • Growing the recycling materials market.

  • All parts of the recyclate chain have taken a keen interest in this area and regulation development – as have Ministers and several Government Departments.


Public consultation
Public Consultation

  • Consultation published on 1 February 2013 on proposed draft MRF regulation;

  • 88 responses (inc representative bodies)

  • Local Authorities - 42

  • Waste Management Co - 11

  • Reprocessors / Manufacturers - 23

  • Other prof/rep/trade bodies - 4

  • Other (consultancies, interest

    groups, campaign bodies) - 8


Key issues from consultation
Key issues from consultation

  • Preference for Environment Agency carrying out inspections and compliance checks, over having a third (independent) party audit doing so;

  • Most respondents wanted sampling regime strengthening from initial proposals;

  • Calls to drop proposal for requirement to sample residual waste streams, predominantly on health and safety grounds;

  • Looking for a balance between robust sampling regime and operational/economic pragmatism.




Key elements of the final regulations
Key elements of the final Regulations Regulations 2014 (schedule 9A)

  • Retain1000 tonne threshold to exempt smaller MRFs from the regulations: but kept under review;

  • Inspection (audit) regime provided by EA & NRW;

  • Transitional approach to some sampling frequencies;

  • Increase over initial sampling levels/requirements;

  • Retention of 6-month transition period (until October 2014);

  • Individual local authorities to be able to track information on the recycling material they supply.


Sampling
Sampling Regulations 2014 (schedule 9A)

  • Reflects balance between robustness and practicality;

  • Transitional approach to sampling frequencies spread over a 2-year period from implementing the regulations.

    Input:

  • 60kg of input material sampled per 160 tonnes of throughput during first two years for each supplier, reducing to once every 125 tonnes;

    Output:

  • 50kg of paper output material sampled once every 80 tonnes in throughput in first two years, followed by once every 60 tonnes;

  • 20kg of plastic output material sampled once every 20 tonnes of throughput in first two years, followed by once every 15 tonnes;

  • 10kg of glass output material sampled once per 50 tonnes of throughput;

  • 10kg of metal output material sampled once per 20 tonnes.


Inspection regime will be undertaken by
Inspection regime will be undertaken by: Regulations 2014 (schedule 9A)

  • England

  • Wales


Outline of inspection details
Outline of inspection details Regulations 2014 (schedule 9A)

  • Agency to undertake one announced and unannounced inspection to all MRFs per year, to check quality assessment & reporting system;

  • Those MRFs considered underperforming would receive follow up visits, advice and ultimately enforcement action if necessary;

  • Environment Agency due to launch a public consultation on proposed charging regime for their MRF inspections;

  • NRW also to consult in due course.


Conclusion
Conclusion Regulations 2014 (schedule 9A)

Regulations are substantial and positive step:

  • Supporting economic growth by maximising the value of the recycled material collected;

  • Promoting higher income from sale of quality recyclates;

  • Delivering confidence about reliable stream of recovered material and may encourage investment in the sector;

  • Allowing local authorities and waste management companies to demonstrate co-mingling is capable of delivering high quality recycling.

    .


Thank you Regulations 2014 (schedule 9A)


  • Mike Jefferson

  • Director, Verde Recycling Solutions


Background
Background Regulations 2014 (schedule 9A)

  • Guidance to support the Regulations.

  • Will be available on the WRAP website inApril.

  • Development supported by a steering committee with representation from Government, regulators, the waste industry and reprocessors.

  • Separate Defra guidance is also being prepared.

  • Prepared by LRS Consultancy with Verde Recycling Solutions, Waste Intelligence and International Safety Services.


Introduction1
Introduction Regulations 2014 (schedule 9A)

  • Non statutory (but with input from regulators).

  • A practical guide explaining the requirements of the Regulations.

  • Gives best practise guidance.

  • Will help ensure a high quality consistent approach to sampling.

  • Facilities (MF) can adapt sampling techniques to fit individual circumstances.

  • Highlights the potential operational and commercial benefits of sampling.


Do you operate a mf
Do you operate a MF? Regulations 2014 (schedule 9A)

  • A regulated facility or part of a regulated facility that receives mixed waste material in order to separate it into specified output material for the purpose of selling it, or transferring it to other facilities or persons to enable that material to be recycled by those facilities or persons.

  • The Regulations apply to MFs that receive 1,000 tonnes or more of mixed waste materialfor sorting in four consecutive reporting periods (each reporting period is three months)


What is mixed waste material
What is Mixed Waste Material? Regulations 2014 (schedule 9A)

  • Waste that:

  • (a) originates

  • (i) from households, or

  • (ii) from other sources but is similar to household waste in terms of its nature or composition; and

  • (b) consists in the largest proportion of two or more of the following kinds of target materials mixed together:

  • (i) glass;

  • (ii) metal;

  • (iii) paper;

  • (iv) plastic. 


What does this mean in practice
What does this mean in practice? Regulations 2014 (schedule 9A)

  • Mixtures of materials from non household sources containing plastic bottles, glass bottles and jars, cardboard, drinks cans, etc.

  • Typical non household sources would be pubs, restaurants, universities and offices.

  • Additional advice on what might be considered ‘similar to household’ in the Defra guidance – size of plastic containers and trays, types of cardboard, etc.

  • Streams such as household WEEE, textiles, residual and organics not covered by the Regulations.


Examples of specified output materials output grades
Examples of specified output materials Regulations 2014 (schedule 9A)(output grades)

  • HDPE bottles

  • PET bottles

  • Natural HDPE bottles

  • Coloured HDPE bottles

  • Clear PET

  • Coloured PET

  • PTT

  • Domestic films

  • Mixed bottles

  • Clear (flint) glass

  • Brown (amber) glass

  • Green glass

  • Mixed glass

  • OCC

  • ONP

  • Mixed paper

  • Aluminium UBCs

  • Steel food and drinks cans

  • MF sets their own output grades


MF (subject to input volumes) Regulations 2014 (schedule 9A)

Not likely to be a MF

Waste transfer stations acting only as bulking points (so with no sorting activities).

Waste transfer stations that sort C&I wastes.*

Household Waste Recycling Centres (Civic Amenity Sites).

C&I MRF’s *

MRFs treating only residual waste (‘Dirty’ MRFs).

Mechanical Biological Treatment (MBT) plants including those used at autoclave facilities unless mixed waste material is accepted for any MRF operations that form part of the process.

Refuse Derived Fuel (RDF) production facilities.

WEEE management facilities.

MRF’s separating materials from construction and demolition waste.

  • Material Recovery Facilities (MRFs) sorting household dry recyclables.

  • Commercial waste treatment operations and transfer stations where materials similar to household wastes are sorted intospecified output material

  • * Unless the commercial waste meets the definition of Mixed Waste Material..


Sampling weights and frequencies
Sampling weights and frequencies Regulations 2014 (schedule 9A)

  • Frequency of sampling calculated on a rolling basis


Sampling weights and frequencies1
Sampling weights and frequencies Regulations 2014 (schedule 9A)

  • To 1st October 2016


Example mf input scenario
Example MF input scenario Regulations 2014 (schedule 9A)

  • To 1st October 2016


Example mf output scenario
Example MF output scenario Regulations 2014 (schedule 9A)

  • To 1st October 2016


Example schedule that might be developed
Example schedule that might be developed Regulations 2014 (schedule 9A)


Taking samples
Taking samples Regulations 2014 (schedule 9A)

  • For incoming mixed waste material:

  • By supplier.

  • Sample sizes may fall to 55kg so long as the average over the reporting period is 60kg.

  • For output material:

  • Sampling by grade, e.g. for paper outputs this might be by OCC, newspapers and magazines, mixed paper, etc.

  • No ability to go below the required sample weight.

  • Not required where material arrives pre-sorted.

  • Not required for the residual fraction.

  • Samples should be taken in one go.


Supplier
Supplier Regulations 2014 (schedule 9A)

  • For material collected pursuant to arrangements made by a waste collection authority under section 45(1)(a)or(b) of the Environmental Protection Act 1990 that authority is the supplier;

  • Where the batch is transferred from another MF then they are the supplier;

  • If non of above then the supplier is the person who collected the material or if not known the person responsible for delivering it.


Step by step guidance on taking samples
Step by step guidance on taking samples Regulations 2014 (schedule 9A)

  • Scheduling of sampling.

  • Based on Regulations and predicted deliveries.

  • Taking representative samples (different days, shifts, times, etc).

  • Isolating the sample.

  • Take samples for:

  • Loose input and output material.

  • Incoming bagged material.

  • Baled material.

  • Labelling, storage & transport.

  • Sampling from bulking points.


Guidance also provided for
Guidance also provided for Regulations 2014 (schedule 9A)

  • Separating a suitable weight of material.

  • Randomising the sample.

  • Taking a representative sample.

  • Taking a sample using techniques such as slice of pie, direct tipping or points of compass techniques.

  • Taking samples from loose bulked material or from conveyors.


Sampling good practise Regulations 2014 (schedule 9A)

Sampling bad practise

Avoid taking samples just from the top or bottom of a pile.

Do not include exceptional items that would ordinarily be removed prior to processing.

Avoid use of built in scales on mobile plant.

Do not test more than one sample at once to minimise cross contamination risks.

Do not ‘adjust’ a sample in an attempt to make it representative.

  • Having a training programme in place.

  • Having a sufficient number of trained staff.

  • Modify the day and time when samples are taken to ensure results are representative.

  • Automate sample taking where possible.

  • Ensure samples are corrected labelled and stored.

  • Containers marked with appropriate fill levels.

  • Undertake spot checks on sampling results.


Testing of samples
Testing of samples Regulations 2014 (schedule 9A)

  • Samples are split into two size fractions (using a 12mm x 12mm screen for glass and 45mm x 45mm screen for other materials).

  • Larger fraction sorted into target material, non target material and non recyclable material.

  • Smaller fraction (material particles) allocated as per the larger fraction.

  • For incoming mixed waste material the target material needs to be split into a minimum of metal, plastic, glass and paper.

  • Supporting evidence should be kept as to how wastes have been categorised (reprocessors specifications).

  • Covered step by step in the guidance.


Target materials
Target materials Regulations 2014 (schedule 9A)

  • For incoming mixed waste material this includes all items that are requested for collection in that fraction.

  • Includes integral parts of targeted materials (bottle caps, neck rings, etc) unless specifically excluded in specifications.

  • Includes the following items unless they are classed as a contaminant in the reprocessor’s specification:

  • Aluminium foils and aerosols in UBCs.

  • PET trays in PET bottles (of the correct colour).

  • Wet paper unless it is degraded to the point where it is not fit for recycling.

  • Contaminants can be of the same material type (coloured glass in clear glass, OCC in newspapers and magazines, etc).

  • Care is needed with respect to what is allowed up to a certain percentage and contaminants with a tolerance.


Testing other
Testing (other) Regulations 2014 (schedule 9A)

  • Where different reprocessors are supplied with the same output grade (each with their own specification) then a common sense approach is proposed to defining target materials.

  • Cardboard and cartons that include cardboard as a composite material should be included in the paper category.


Testing good practise Regulations 2014 (schedule 9A)

Testing bad practise

Not clearing /cleaning containers and the work area between testing different samples.

Not isolating testing from other on site activities (H&S and cross contamination risks).

Forcing or persuading material through the sorting mesh.

Weighing samples outside and / or near moving vehicles (H&S and weighing error risks).

  • Ensure ergonomics of the testing area are optimised (H&S and sorting speed / accuracy).

  • Ensure those testing are fully trained.

  • Provide sufficient containers.

  • Do not overfill containers.

  • Containers should be clean and dry.


Typical equipment
Typical equipment Regulations 2014 (schedule 9A)

  • Platform scales

  • Bench scales

  • Calibration weights

  • Shovels / brooms

  • Containers (sample / sorting)

  • Screens

  • Sorting table

  • PPE

  • Long handled wire cutters

  • Pickers / sharps bin

  • Sampling sheets

  • Loading shovel

  • Automated bin lifts

  • Mini sort conveyors


Sampling statistics
Sampling statistics Regulations 2014 (schedule 9A)

  • Reporting of average target material content and standard deviation for each supplier (waste in) and output grades required.

  • The standard deviation provides a measure of how much variation there is from the average for the target material content across the sampling results

  • Objective: high average target material content with low standard deviation.

  • Overview of other statistical analysis that could be carried out using the data.

  • Commentary on interpretation of statistics.


Sampling statistics1
Sampling statistics Regulations 2014 (schedule 9A)


Health and safety
Health and Safety Regulations 2014 (schedule 9A)

  • Layout and structure of the sampling area.

  • Vehicle movements & operating procedures.

  • Pedestrian access to sampling areas.

  • Safe systems of work.

  • Sampling from bales and from conveyors.

  • Manual handling.

  • Hygiene risks and handling hazardous waste.

  • PPE.


Other areas included in the guidance
Other areas included in the guidance Regulations 2014 (schedule 9A)

  • Staff training (including H&S).

  • Enforcement of the Regulations.

  • Reporting templates.

  • Questions and answers.

  • Flowcharts.


Acknowledgements
Acknowledgements Regulations 2014 (schedule 9A)

  • Convention of Scottish Local Authorities

  • Defra

  • Environment Agency

  • Environmental Services Association

  • Kent Resource Partnership

  • Local Government Association

  • Natural Resources Wales

  • Northern Ireland Environment Agency

  • Resource Association

  • Resource Futures

  • Scottish Environmental Protection Agency

  • SITA UK

  • Veolia Environmental Services

  • Viridor

  • Welsh Government


  • Steve Waite

  • MRF Sector Specialist


Presentation
Presentation Regulations 2014 (schedule 9A)

  • Introduction

  • What has to be reported in the MF Regulations ?

  • Why do we need the portal ?

  • WRAP Reporting Portal

  • Potential options for inputs

  • Potential options for outputs

  • Advantages and Challenges

  • Timescale

  • Presentation will only give a general overview as the detail has yet to developed


What has to be reported 1
What Has To Be Reported 1 ? Regulations 2014 (schedule 9A)


What has to be reported 2
What Has To Be Reported 2 ? Regulations 2014 (schedule 9A)


What has to be reported 3
What Has To Be Reported 3 ? Regulations 2014 (schedule 9A)


Standard error and confidence
Standard Error and Confidence Regulations 2014 (schedule 9A)

  • If standard deviation and number of samples are provided

  • Standard error = SD/√n

  • At a stated confidence level (95% has a z=1.96)

  • Then mean range = mean +/- (1.96 x standard error)


Why do we need the portal
Why Do We Need The Portal ? Regulations 2014 (schedule 9A)

  • Need to be able to understand the quality of materials being delivered into and despatched from MFs.

  • Regulator public registers may not provide sufficient detail.

  • Maximise ease of access by stakeholders.

  • To be able to easily locate particular suppliers or MFs an electronic portal with search facilities.


Schematic draft layout of wrap portal
Schematic Draft Layout of WRAP Portal Regulations 2014 (schedule 9A)

WRAP PORTAL

Regulator (EA)

Data Validated

MFs Electronically Provide Quarterly Data

Opportunity for other Regulators

Registered Stakeholders Access Portal


Potential options for inputs
Potential Options For Inputs Regulations 2014 (schedule 9A)


Potential options for outputs
Potential Options For Outputs Regulations 2014 (schedule 9A)


Potential further searches
Potential Further Searches Regulations 2014 (schedule 9A)

  • Information by Nation

  • Information by Region

  • Information by type of local authority

  • Information by size of MF


Advantages
Advantages Regulations 2014 (schedule 9A)

  • Straight forward way to access information.

  • Will allow a degree of comparison between local authorities and MFs.

  • Will allow MF to be considered against material received and despatched.

  • Will be able to get results by quarter


Challenges
Challenges Regulations 2014 (schedule 9A)

  • Acceptance by Industry

  • Results being used in context

  • Dealing with the different interpretations of material grades

  • Differentiating between a waste management company supplier and waste management company operator.


Timescale
Timescale Regulations 2014 (schedule 9A)

  • The first reporting period is October 1st to December 31st.

  • MFs have one month beyond 31st December to provide their results.

  • Portal to be tested for end of 2014 and ready to receive the first set of validated data from 1st February 2015.


Thank you
Thank You Regulations 2014 (schedule 9A)

  • [email protected]


Mf regulations workshop role of the regulator chris bower environment business advisor 4 march 2014

MF Regulations Workshop - Regulations 2014 (schedule 9A)Role of the RegulatorChris BowerEnvironment & Business Advisor4 March 2014


Contents Regulations 2014 (schedule 9A)

  • Context

  • Regulatory framework

  • Timeline

  • Who’s in

  • Who’s outside

  • Notifications

  • Reporting

  • Inspections

  • Enforcement

  • What reported data may show

  • Charges

  • Concluding messages


Context Regulations 2014 (schedule 9A)

  • Regulations are intended to promote high quality recycling.

  • By publishing the quality of incoming wastes and outgoing recyclates at qualifying Materials Facilities

  • MF Reg inspections will be a discrete piece of additional work at these sites

  • Part of a wider approach

    • Envt’l protection, Waste Stream Audits, Duty of Care, TFS

    • Quality Action Plan (England)

  • NRW has its own approach in Wales


Regulatory Framework Regulations 2014 (schedule 9A)

  • The Environmental Permitting (England and Wales) (Amendment) Regulations 2014

    • Coming into force in England 5 March 2014

    • Schedule 9A Materials Facilities October 2014

    • Introduces requirements directly into qualifying permits effectively as a Condition

    • Operators assess to decide if qualify and notify regulator if do

    • to sample, assess and report on quality if qualify


Timeline Regulations 2014 (schedule 9A)

  • March 2014 Consultation on charges starts

  • April Guidance published.

  • We write to operators.

  • Operators can notify and start preparations

  • July Charging arrangements in place.

  • We can formally start advisory visits

  • - to those sites who have notified

  • October First 3 month reporting period starts

  • Operators start sampling

  • Jan 2015 First reported data due from operators.

  • TBA First quarter results published


Who’s in? Regulations 2014 (schedule 9A)

  • MRFs that handle 1000t pa or more of mixed waste.

  • A MF is a permitted facility that separates mixed waste into specified output material

  • Mixed waste is household or similar and comprises 50% or more of at least two of glass, plastic, paper or metal


Who s outside
Who’s outside? Regulations 2014 (schedule 9A)

  • Waste transfer or bulking activities not involving sorting.

  • Sorting just one stream , eg paper alone

  • Incoming waste is unlike household or does not contain target mt’ls

  • Household waste recycling facilities (civic amenity sites)

  • Industrial MRF taking large sized waste (e.g. in skips), not comprising household or household-like waste.

  • Only treating residual waste (‘dirty’ MRFs)

  • Mechanical Biological Treatment (MBT) unless mixed waste material is accepted for any MRF operations that form part of the process.

  • Refuse Derived Fuel plant without a sorting facility.

  • Waste Electrical and Electronic Equipment is excluded.

  • Separating only construction and demolition waste

  • Activities authorised by Exemptions


Notifications
Notifications Regulations 2014 (schedule 9A)

  • Quarterly assess if your facility qualifies

  • Notify us if you think it qualifies (we will provide email address for notifications)

  • You only need to notify once, not every quarter

  • The notification remains until withdrawn by you

  • You can withdraw notification e.g. if a future assessment indicates you no longer qualify

  • If you are unsure whether you qualify, refer to guidance and contact us for advice


Reporting
Reporting Regulations 2014 (schedule 9A)

  • Electronically, quarterly - 1 month after qtr end

  • Quarters: Jan-Mar, Apr-Jun, Jul-Sept, Oct-Dec

  • Data will go on public register

  • First reports are due by 31 January 2015

  • See Schedule 9A for details of what needs to be reported

  • Reported data will be published


Inspections
Inspections Regulations 2014 (schedule 9A)

  • Awareness visits.

  • Announced inspections

    • Inspecting management, systems, reality checking bales against reported data

    • Will require a bale to be broken and re-assessed if concerned

  • Unannounced inspections

    • Focus on areas of potential weakness

  • Further visits to underperformers

    Q: Are we interested in customer complaints? Yes, for our info.

    Q: Will inspection reports be available? Yes, public register.


Enforcement
Enforcement Regulations 2014 (schedule 9A)

  • General approach to enforcement and sanctions applies here.

  • Will be treating the following failures as a breach of the permit:

    • Failure to notify

    • Failure to measure inputs to and outputs from the facility

    • Failure to sample at the required frequency & weights

    • Failure to record

    • Failure to report

  • Advice, Warnings, Enforcement Notices

  • If you are meeting guidance then unlikely to be any issues.


What reported data may show
What reported data may show Regulations 2014 (schedule 9A)

Not settled yet but may cover:

  • Which facilities are qualifying MFs

  • Who supplies them, including waste authorities

  • The amount of mixed waste treated at qualifying MFs

  • % non-recyclable material in sampled mixed waste inputs

  • Quantities of specified output material leaving MFs

  • Composition of sampled specified output materials by target, non-target and non-recyclable material

  • Quantities and destinations of Other Waste leaving the MF

  • Quantities & destinations of mixed waste sent to another MF


Charges
Charges Regulations 2014 (schedule 9A)

  • We need new income to specifically fund this MF Regulation work

  • Arrangements still being developed

    • triggered by notification or actual tonnage processed?

  • Likely to be an additional subsistence charge of circa £2k for MFs

    • Same for everyone, at this stage, because visiting everyone & extra visits small aspect

  • Lower charge for 2014 as start up year.

  • Billing likely to be each April, for previous calendar year

  • Could consider move to performance-related charges in future


Concluding messages
Concluding messages Regulations 2014 (schedule 9A)

  • We are involved to provide confidence in the data

    • There are practical limitations around what we can do

  • MF Reg work will be a discrete additional piece of work

    • On data reporting, not advising on improving quality

    • Part of a wider picture

  • We want to work with business to deliver the aims


What is a supplier
What is a ‘supplier’? Regulations 2014 (schedule 9A)

See Schedule 9A butpara phrased is:

a) waste collection authority, where collected under section 45(1)(a) or (b) of the Environmental Protection Act 1990

b)MF where mixed waste is transferred from that MF to another material facility

c)if not (a) or (b), the person who collected the material or, if that person is not known, the person responsible for delivering it to the MF

d) where the batch is from more than one supplier the MF can estimate and apportion tonnage per supplier


  • Q&A Regulations 2014 (schedule 9A)


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